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					Item No.                   Classification                 Decision Level        Date

6.2                        OPEN                           PLANNING COMMITTEE      3/7/2007

From                                                      Title of Report


Proposal (06-AP-2117)                                     Address

Erection of three buildings (maximum height 180m          LAND BOUNDED BY BLACKFRIARS
Above Ordnance Datum Level / 52 storeys plus              ROAD, STAMFORD STREET,
basement levels) providing a mixed use scheme             RENNIE STREET & UPPER
totaling 77,023m² Gross External Area comprising          GROUND, LONDON, SE1 9UF
36,267m² of Class C1 (hotel) comprising 261 rooms,
associated facilities including a business centre, spa,   Ward Cathedrals
wellness centre/gym, restaurants and bars;
26,778m² of Class C3 (residential) use comprising
96 flats; 1,122m² of Class D2 use as a Sky Deck for
observation and function areas; 911m² of Class A
uses (372m² of Class A3 restaurant use, 46m² of
retail, and 493m² of flexible Class A Use); 11,935m²
of ancillary plant, servicing and car parking.


1     To consider the above application, which is for Planning Committee consideration due
      to the strategic nature of the proposals and the number of objections received.


2     (a) Minded to grant planning permission.

      (b) This application to be reported back to Committee in October, once planning
      obligation details have been finalised, with a recommendation to resolve to grant
      permission, subject to a S106 agreement and reference to both the London Mayor and
      the Government Office for London.


      Site location and description
3     The application site is located on the north west corner of the main road junction of
      Blackfriars Road and Stamford Street. The site is an entire street block bounded by
      Upper Ground to the north and Rennie Street to the west, and orientated north-south
      and approximately 96m long by 60m wide, occupying an area of 0.77 hectares. At
      present the entire site has been cleared of all buildings to basement level and the
      centre of the site is 6m below surrounding ground levels.

4     Prior to demolition a few years ago, the site was occupied by 2 inter-linked office
      buildings, both of which were used by Sainsbury’s as their main office headquarters.
      One was Drury House, an office building dating from the 1960’s, 12 storeys high with a
      4 storey wing. The other was Stamford House, fronting Rennie Street, which was an
      Edwardian (1912) design 5 storey office building.
5    The surrounding area is a mix of commercial office uses, with 2 residential
     developments, Rennie Court to the west and River Court to the north and north west,
     together with some retail shops nearby. There are a number of listed Grade II
     buildings nearby. Immediately to the south is 1 Stamford Street, a Victorian
     commercial building, 3 storeys in height with dormers to mansard (c1870) and 3
     Stamford Street (c1875) is a four-storey commercial building. Blackfriars Bridge and
     Unilever House on the north side of the river are also listed Grade II.

     Details of proposal
6    The proposed development would be in three parts. A single storey podium which
     extends across the whole site and forms a base for the six storey residential block
     along the Rennie Street frontage and a mixed use tower rising to 180m above
     ordnance datum (AOD) level. A public plaza would be provided above the podium
     level, at the base of the tower and with shops and cafes.

7    The tower will be a slender building with a curved leading edge facing NNE towards
     Blackfriars Bridge and a distinctive profile where the north-south cross-section of the
     building increases in depth from a small foot print to its widest point at levels 32 and 33
     and then tapers to its summit at floor level 52. The first three floors from ground level
     upwards would be occupied primarily by entrances, lifts and plant rooms. From floors 3
     to 24 of the tower there will be a 5-star, 261 room hotel, this will have a restaurant,
     gymnasium, sauna, spa and swimming pool on floors 25 to 27. Floors 28 to 49 will
     have 64 private residential apartments and a publicly accessible Sky Deck on levels
     50 and 51. The hotel would have its main entrance on Blackfriars Road and the flats
     would have a separate ground level access on the corner of Blackfriars Road and
     Upper Ground. The public access to the Sky Deck would be from the Plaza on level 1.

8    At street level, the Rennie Street Block will be mainly entrances to the flats and
     business centre above, plant rooms, vehicle entrances and, at the southern end, the
     entrance lobby to the ballroom below. The vehicle entrance and exit from the
     basement car park will be in Rennie Street (using 2 car lifts) and the entrance and exit
     for servicing / delivery lorries will be via 2 lorry lifts in Upper Ground. At first floor level
     will be shops and a café facing onto the Plaza and hotel and Sky Deck administrative
     offices. On the 2nd and 3rd floors the southern half of the building will be occupied by
     a business centre and the northern half will be flats. On the 4th and 5th floors the
     northern half will also be residential with the remainder as plant rooms. On the roof
     above the flats there will be rows of solar hot water collectors. The 32 flats in this block
     will all be for affordable occupation, built to Lifetimes Homes standard and 4 will be
     ‘wheelchair’ units.

     There will be four basement levels. A ballroom and conference centre will occupy the
9    southern half of basement levels 1 and 2, with the northern half being occupied for
     deliveries, storage, the biomass boiler and two lorry lifts. In basement levels 3 and 4
     will be 79 car parking spaces, 24 motor cycle and 112 bicycle parking bays (plus 36 at
     ground level in the Rennie Street Block). The cars will be subject to valet parking
     management and accessed via the two car lifts.

     The scheme will total some 77,023m² Gross External Area comprising a hotel of
10   36,267m², including associated facilities such as a business centre, spa, wellness
     centre/gym, restaurants and bars; the flats above would occupy 26,778m² of Class C3
     (residential) use comprising 96 flats; the Sky Deck will occupy 1,122m², including
     observation and function areas; 911m² will be for Class A uses (372m² of Class A3
     restaurant use, 46m² of retail, and 493m² of flexible Class A Use); and a further
     11,935m² of ancillary plant, servicing and car parking.

     Planning history
     Planning permission was granted on 8th January 2002 for the redevelopment of the
11   site to provide a part 19 storey (85m AGL / 90m high AOD) building, and part 7 and
     part 5 storey building for office use with supermarket use on the ground floor together
     with the creation of a public open space on the north west corner of the site, with the
     provision of car, cycle and motor cycle parking and service area and other works.
     (Reg. No. 0100649). Designed by Foster and Partners, the new building would
     comprise 43,856 square metres of office space and a 2,418 sq.m. supermarket. There
     would also be associated servicing with 25 car parking spaces, 35 motorcycle spaces
     and 200 bicycle spaces in the basement. This permission was subject to 22 conditions
     and has not been implemented.

12   On 1st November 2006 planning permission was granted (under Section 73 of the
     Planning Act 1990) for the same development but with modified conditions from those
     imposed on the 2002 planning permission. The revised conditions allowed for the
     implementation of the development before some details were submitted and approved.
     As a result the 2006 permission has now been implemented by foundation works
     having been carried out on site.

13   In July 2005 a planning application (05-AP-1545) was submitted for the redevelopment
     of the site for a similar development as that now being considered but with a 69 storey
     tower (maximum height 219m AGL / 226m AOD) with 218 flats and a hotel, with 32
     flats in the lower building adjoining Rennie Street. On 14th May 2007 this application
     was withdrawn in favour of the current application.

14   On 30th October 2006 a revised planning application was submitted for a 52 storey
     development. This is the current scheme under consideration.

     Planning history of adjoining sites
15   There are a number of modern developments in the immediate area of varying
     heights. Existing buildings include Kings Reach Tower is 30 storeys, Sea Containers
     House (to the NW) is 14 Storeys, Ludgate House (to the East) is 10 storeys and the
     Kings Reach low level complex is 6 storeys.

16   In the wider area there are also new developments at Bankside, including the recently
     completed Bankside 1-2-3 development in Southwark Street, and the ‘Palestra’ at 197
     Blackfriars Road.

17   In addition, to the existing tall buildings in the area, there are a number of current
     proposals to develop sites in this area and a number of pre-application expressions of
     interest in redeveloping other sites in the area. The most significant of those where
     permissions have been granted, or resolved to be granted subject to directions by
     other authorities, are Kings Reach, 240 Blackfriars Road, Bankside 4 and Tate Modern
     2. In summary these are:
     (a) Bankside 1-2-3 – 13 storey, 107,793 m2 offices, 7,438 m2 retail/A3 (granted and
     Bankside 1 occupied, rest nearing completion)
     (b) Palestra, 197 Blackfriars Road – 12 storey, 37,451 m2 offices (completed)
     (c) Kings Reach, Upper Ground, involves an extension to 34 storeys, with 47,949 m2
     offices and 3,006 m2 retail (granted);
     (d) Wedge House, 32-40 Blackfriars Road – 10 storey, 10,375m2 offices (resolution to
     (e) Bankside 4 – 5 buildings of 24, 18, 12, 12 and 6 storeys, providing 229 flats over
     retail, leisure and amenity space (resolution to grant, November 2006). This also
     replaces the Hopton Street Tower permission for a 20 storey, 48m/63m high
     residential building with amenity and leisure space.
     (f) 240 Blackfriars Road – 15 storey, 25,293sq.m. offices over restaurant, and 5 storey
     block of 10 flats above retail (resolution to grant, March 2007); and
     (g) Tate Modern 2 – 76m high extension to Tate Modern (resolution to grant, March

18   There is also a current application for the redevelopment of a site at 20 Blackfriars
     Road for a development comprising two towers. A 42 storey (148m high AOD)
     residential tower for 167 market flats and 52 intermediate sector flats, and a 23 storey
     (105m AOD) office tower.

19   There are also a great many other tall building proposals in Southwark and elsewhere
     in central London, including London Bridge Tower (‘The Shard’, 306m); Castle House
     (147m high) and London Park Hotel (145m) at Elephant & Castle; One Canada
     Square (235m), Riverside Towers 1 and 2 (241m & 191m), and the HSBC and Citicorp
     Towers (both 210m) at Canary Wharf; and Tower 42 (183m); Bishopsgate Tower
     (’Helter Skelter’, 288m); 122 Leadenhall St. (‘The Cheese Grater’, 225m); Heron
     Tower (258m), 30 St. Mary Axe (‘The Gherkin’, 180m); Broadgate Tower (178m) and
     20 Fenchurch Street (‘Walkie Talkie’, 160m) in the City; and Doon Street (168m) in

20   The applicants, The Beetham Organisation, have already built two Beetham Towers
     previously with Ian Simpson Architects. The Beetham Tower in Liverpool is 90m high
     and the tower in Manchester is 171m high.


     Main Issues

21   The main issues in this case are:

     a] the principle of the development in terms of land use and conformity with strategic

     b] whether a tall building of this scale and design would be acceptable on this site;

     c] whether this development is of world-class architectural quality, an inclusive, safe
     and sustainable development, and does not result in significant adverse impacts for
     the amenity of neighbouring residential properties and the surrounding area; and

     d] creates suitable improvements to the public realm and local environment.

     Planning Policy
22   At its meeting on 28th March 2007 the Council resolved to adopt the emerging
     Southwark Unitary Development Plan [Modifications version March 2007] subject to
     consultation on revised wording in respect of policies 4.1, 4.2 and 4.4 prior to formal
     adoption in June 2007. Whilst the 1995 Unitary Development Plan remains the
     statutory development plan until such time as the emerging plan is formally adopted,
     the Council will give predominant weight to the 2007 plan policies in determining
     pending applications unless material considerations indicate otherwise.

23   Emerging Southwark Plan 2007
     The site is located within the Central Activities Zone
     The site is within the Preferred Office Location
     The site is within the Bankside and the Borough Major Town Centre
     The site is within an area of District Park Deficiency
     Policy 1.3 Preferred Office Locations
     Policy 1.7 Development within town and local centres
     Policy 1.11 Arts, culture and tourisms uses
     Policy 2.5 Planning Obligations
     Policy 3.1 Environmental Effects
     Policy 3.2 Protection of Amenity
     Policy 3.3 Sustainability Assessment
     Policy 3.4 Energy Efficiency
     Policy 3.5 Renewable Energy
     Policy 3.9 Water
     Policy 3.10 Efficient Use of Land
     Policy 3.11 Quality in Design
     Policy 3.12 Quality in Design
     Policy 3.13 Urban Design
     Policy 3.14 Designing Out Crime
     Policy 3.15 Conservation of the Historic Environment
     Policy 3.18 Setting of Listed Buildings, Conservation Areas and World Heritage Sites
     Policy 3.19 Archaeology
     Policy 3.20 Tall Buildings
     Policy 3.21 Strategic Views
     Policy 3.22 Important Local Views
     Policy 4.2 Quality of Residential Accommodation
     Policy 4.3 Mix of Dwellings
     Policy 4.4 Affordable Housing
     Policy 4.5 Wheelchair Affordable Housing
     Policy 5.1 Locating Developments
     Policy 5.2 Transport Impacts
     Policy 5.3 Walking and Cycling
     Policy 5.6 Car Parking
     Policy 5.7 Parking Standards for the Mobility Impaired
     Policy 5.8 Other parking
     Policy 7.4 Bankside and The Borough Action Area

24   London Plan 2004
     Policy 2A.1 – Sustainability Criteria
     Policy 3A.14 Addressing the needs of a diverse population
     Policy 3C.22 – Parking Strategy
     Policy 4A.7 – Energy efficiency and renewable energy
     Policy 4A.8 – Energy Assessment
     Policy 4A.9 – Providing for renewable energy
     Policy 4A.10 – Supporting the provision of renewable energy
     Policy 4B.1 – Design principles for a compact city
     Policy 4B.2 – Promoting world-class architecture and design
     Policy 4B.3 – Maximising the potential of sites
     Policy 4B.4 – Enhancing the quality of the public realm
     Policy 4B.5 – Creating an inclusive environment
     Policy 4B.6 – Sustainable design and construction
     Policy 4B.7 – Respect local context and communities
     Policy 4B.8 – Tall Buildings – location
     Policy 4B.9 – Large scale buildings – design and impact
     Policy 4B.10 - London’s Built Heritage
     Policy 4B.11 – Heritage Conservation
     Policy 4B.14 - Archaeology
     Policy 4B.15 – London View Protection Framework
     Policy 4B.16 – View Management Plans
     Policy 4B.17 – Assessing development impact on designated views.
     Policy 4C.26 – Appraisals of the Thames Policy Area
     Policy 5B.2 – Development in the Central Activities Zone
25   Planning Policy Guidance [PPG] and Planning Policy Statements [PPS]
     PPS1 – Delivering Sustainable Development
     PPS3 – Housing
     PPS22 – Renewable Energy
     PPG13 – Transport
     PPG 15 – Planning and the historic environment
     PPG 16 – Archaeology and planning


26   Site Notices 16/11/2006
     Press Notice 15/11/2006

27   Internal Consultees
     Design and Conservation Team
     Transportation Group
     Public Protection

28   Statutory and non-statutory consultees
     English Heritage
     London Mayor
     City of London
     City of Westminster
     London Borough of Lambeth
     London Borough of Camden
     Royal Parks

29   Neighbour consultees: Flats 1 – 99 Rennie Court; Rennie House, 15-23 Rennie St;
     Kings Reach Tower; Flat 1 – 87 River Court; 1-14 Milroy Walk; 1, 19 - 26, 231-241,
     242, and Ludgate House, 245 Blackfriars Road; 3 -17, 23 - 45 Stamford Street; 118
     Southwark Street; Sea Containers House, 20 Upper Ground; New Kings Beam House,
     22 Upper Ground

     Consultation replies

30   Internal Consultees
     Archaeologist – if consent granted an archaeological watching brief is to be
     undertaken during the reduction of the site to the lower basement levels. Conditions

31   Statutory and non-statutory consultees
     London Mayor: Has concluded that the proposal is acceptable in strategic planning
     terms, subject to a number of S106 matters. These being the identification of suitable
     sites for the provision of the off-site affordable housing, an investigation of a
     mechanism for an equity stake in value appreciation and/or a commitment to re-invest
     in affordable housing, further analysis of the financial appraisal, identification of new
     off-site children’s play space, and various transport matters. Appropriate conditions will
     be required to ensure design quality. Further information is required as to why
     trigeneration has been rejected and other energy issues. An access statement and
     confirmation that there will be 100% Lifetime Homes and 10% wheelchair housing will
     be provided, and details of training, employment and child care provisions.

     English Heritage: Redevelopment of this site is acceptable in principle and we are
aware of the extant permission for the construction of an 85m high tower designed by
another architect on this site. Welcome the architect’s wish to construct a distinctive
building. However the construction of a tower, at either 226m or 178m high, in this
location, would cause significant harm to London’s historic environment.

English Heritage wishes to raise the strongest possible objection to these proposals on
a number of grounds:

(a) By virtue of its bulk, massing, height and scale, the proposed building would cause
an unacceptable degree of harm to significant cross London views. Most significantly
from St. James’s Park, Waterloo Bridge and other river views. These are amongst the
26 strategic views which the ‘London View Management Framework’ seeks to manage
and protect. Views along the River Thames from Waterloo , Southwark and Blackfriars
Bridges would be dominated by a building of this scale;

(b) There would be significant harm to historic assets of national importance. The
Whitehall and St. James’s Conservation Areas are of more than local significance and
St. James’s Park is a Grade 1 Registered Landscape. There would be significant harm
to all of these assets. In particular, the settings of both Conservation Areas, and of the
Park, would be damaged because of the harmful effect that the proposal would have
on views towards and into, and out from, those areas;

(c) The planning policy context for determining applications for tall buildings in this
part of London is unresolved. Southwark Council has yet to draft and adopt a tall
buildings policy for North Southwark. Whilst Southwark and Lambeth are considering a
joint Local Development Framework for North Southwark and Waterloo, this is some
way off. The London Plan does not define North Southwark as an Opportunity Area
where intensification and tall buildings might be appropriate. In the absence of a clear
and up to date planning policy context, the consideration of proposals which would
have cross-London impacts of this significance is premature;

(d) The proposals do not comply with guidance issued by the Secretary of State or
English Heritage, in particular the statutory duty to consider impacts of proposals upon
historic buildings and Conservation Areas, and the English Heritage-CABE ‘Guidance
on Tall Buildings’ (endorsed by Government as a material consideration); and

(e) The proposals would also impact adversely at a local level upon the setting of
historic buildings and Conservation Areas across a wider area, particularly in
Southwark, Lambeth and the City of London.

The Royal Parks:

Object to the proposal as the proposed ‘viewing gallery’ will top the current canopy of
trees and existing buildings to become visible from the Blue Bridge within St. James
Park. This is a strategic view mentioned in the London Plan. This would be more
apparent during the winter months. Lit windows at high level would merely contribute
to light leakage into the park.

Westminster City Council – Object for the following reasons:

1. The proposed building by reason of its height and scale will harm views out of, in to
and within and adversely affect the setting of a number of the City Council’s
Conservation Areas as well as the setting of listed buildings within these areas. In
particular, the Strand, Savoy, Whitehall, Westminster Abbey & Parliament Square,
Smith Square, Millbank, and Royal Parks Conservation Areas. The proposal will fail
either to protect or enhance the character and appearance of these Conservation
Areas and will harm the setting of a number of listed buildings therein.

2. The proposed tower, by reason of its height and scale will harm views out of, in to
     and adversely affect the setting of the Palace of Westminster, St. Margaret’s and
     Westminster Abbey World Heritage Site.

     3. The proposed tower by reason of its height and scale will adversely affect local
     views of the River Thames.

     City of London – No objection, note that it will be a prominent landmark on the south
     bank affecting existing river views, across Blackfriars Bridge and the Thames from
     locations on the north bank, such as the Temples.

     Lambeth Council: - Objects on the ground that the proposal would impact adversely on
     the character of the adjoining conservation areas and the setting of listed buildings
     within the London Borough of Lambeth. If it is granted permission, S106 contributions
     should be sought from the developer to mitigate the impact of the development on the
     London Borough of Lambeth. A contribution of £180,615 is sought (£83,115 for
     education, £57,500 for public open space, and £40,000 for transport).

     Tower Hamlets: - Do not wish to offer any adverse comments on the proposal.

     Environment Agency: No objections. Recommend conditions and informatives.

     BAA (British Airports Authority): No objections.
     London City Airport: No safeguarding objection.

     BBC: Where new developments cause reception problems the developer should
     rectify them and this should be in the S106 agreement. Gives advice on identifying
     reception problems and how to overcome them.

     Crime Prevention Design Advisor, Met. Police: No issues.

     South Bank Employers’ Group: does not wish to comment on the scale, design or uses
     of the development but wishes to express its views on the potential community benefit
     which should flow from a development of this scale. They seek contributions from
     Section 106 for Transport and Environment Improvements, including Blackfriars Road,
     and the Riverside Walk. They also seek improvements in Stamford Street and
     Hatfields, improvements for local parks, signage and wayfinding, public toilets, security
     and public safety, employment and training, community and sports facilities, and local

     Southwark Health & Social Care Objects to the proposal as it will not contribute to a
     healthier and sustainable community, and health care provided to existing residents
     will be adversely affected. The nearest GP Practice is the Blackfriars Medical Centre
     on Columbo Street and currently has a patient list of 4,600 and at capacity. There will
     be an additional demand arising from the development. The Primary Care Trust will
     require substantially increased resources for the provision of health care facilities.
     Based upon their calculations they seek a substantial financial contribution for capital
     and revenue costs from this development, to be provided in a planning obligation.
     Neighbour consultees
32   Objectors:
     18 Rennie Court: Will lose daylight and sunlight, and views. There will be an increase
     in noise and traffic. Insufficient services locally for extra demand. High rise
     inappropriate here, will affect views along the Thames.
     42 Rennie Court: Out of character and proportion to area, will reduce daylight and
     sunlight, will increase noise affecting local residents. Will block views. No infrastructure
     to support a hotel, business centre and 96 flats. Increased traffic and congestion, and
     51 Rennie Court: Loss of daylight and sunlight, and overlooking.
     65 Rennie Court: Proposed building will be ugly and overbearing, particularly height
and shape of tower. It will spoil views of St. Pauls from Rennie Court and cut out light.
83 Rennie Court: Too big and too massive. Would support a mixed use scheme on a
smaller scale. Increased traffic with congestion, noise and pollution. Area is presently
pleasant for residents but this will change the area adversely. Will reduce daylight.
87 Rennie Court: Still too high, will cause extra traffic and congestion.
89 Rennie Court: Failure of applicants to consult residents. Too high adjoining Rennie
and River Court, will block light and outlook, increased traffic and access problems.
98 Rennie Court: Will put windows and balcony of flat into shadow. Will lose views of
St. Pauls and Thames. Proposed hotel use inconsistent with office/residential nature of
the area. Conference events will result in traffic and noise day and night. Height is
incongruous with other nearby structures. It will stand out in a garish way.
7 River Court: Must be scaled down. Should be an environmentally friendly
development with gardens on several floors. Traffic and noise from hotel must be kept
away from adjoining residential streets. Impact on daylight.
8 River Court: Will affect light, air and sun. Extra people living, working and visiting
area will add to existing traffic problems and demands on public services.
28 River Court: Tower is too tall, will upset scale of south bank skyline and upstage St.
Paul’s Cathedral. Possible downdraughts. Should be a maximum of 40 storeys.
30 River Court:        Visually intrusive, out of scale and excessively dominant.
Overdevelopment. Increase in foot and vehicular traffic. Will create shadows and wind
intensification. Creates a further barrier to the river.

42 River Court: Extra traffic will put a strain on narrow streets, with noise day and
night, with disruption for existing residents. Water pressure is being reduced by
Thames Water, tower will make matters worse. Are drains adequate? Extra population
will put pressure on existing services. Too high, can cause wind funnelling round base.
Loss of light.
54 River Court: Side roads frequently blocked now, Upper Ground is too small to be
used as the primary delivery access road. The development will block light from my flat
and will overlook flat and terrace garden.
57 River Court: Social housing block will have a lorry access and egress, and
ventilation louvres, facing Upper Ground. Object to noise and pollution from these
features. Lorries will be arriving at all times and be intrusive at unsocial hours. Upper
Ground is already congested by lorries and is a bus route. It will not be possible for
lorries to enter building without causing disruption to other traffic. Congestion will be
caused by proposed drop-off point for cars. Access to River Court garage will be made
difficult. Sainsbury scheme had a small park opposite the flats instead of lorry
entrance. The lorry entrance should be moved further away from River Court. There is
too much crammed into this small site.
69 River Court: Proposal inappropriate for location, will affect skyline, except for Kings
Reach Tower no building higher than 13 storeys. Will menace nearby buildings and cut
out light and be a prime target for terrorist attack. Will require deep foundations which
will undermine adjoining buildings. Disturbance, dust and noise during construction
period. Narrow road could not cope. Noise and disturbance from future extra traffic.
71 River Court: Height will be very intrusive. Water pressure a problem already. Roads
too narrow for extra traffic, do not want to lose RV1 bus route. Needs to be scaled
down to original Sainsbury scheme. Lack of shopping facilities already should carry
out existing approval.
81 River Court: Will cause noise, block light and extra lorries and buses will block
narrow street. Lights in building at night will be disturbance.
83 River Court: Too big, would support a smaller scale scheme. Will increase traffic
and congestion, roads already busy. Will cut out daylight.
86 River Court: Too high, will cut out light to River Court and create wind tunnel effect
down Upper Ground. Upper Ground and Rennie Street too narrow for extra traffic.
Extra cars will add to congestion in the area and will affect bus route RV1.
87 River Court: Will cut out light to River Court. Upper Ground is very narrow and
cannot manage traffic for hotel and extra 96 flats. Do not want to lose bus route RV1.
     No address given: Objects to another tall building, with no relationship to area with a
     high density of residents. Thoughtlessness in the rush to regenerate area.

33   7 Rennie Court: Revised plan has taken into account my objection to noise and has
     also improved the social housing. Now no objections.
     50 Rennie Court: welcome use of site especially lower rise affordable housing with
     green roof and iconic tower. Concern about noise levels.
     20 River Court: Disgusted with lack of progress on the site, just get on with it!
     37 River Court: Will be great for the area.
     78 River Court: The tower will increase the value of the area and then increase local
     services due to increased commercial activity. The designs look nice.
     84 River Court: Will make the area more attractive.

34   Pre-application consultations: The applicant has submitted a Statement of Community
     Involvement, which set out the pre-application consultations that were carried out
     locally. This included three newsletters delivered to some 2000 local households with
     information and invitations to exhibitions. The exhibitions were held on 20th /21st May
     2006 and 16th/17th September 2006 at the London Nautical School, Stamford Street,
     and on 6th / 7th October 2006 at the Mercury London City Hotel, Southwark Street.
     The exhibition had 11 display boards and a model f the scheme. The MP, GLA
     Member, local Councillors, community groups and key stakeholders in the area were
     contacted and invited to exhibitions. (Responses are listed in an Appendix to this
     report.) A further letter was sent to residents in October to inform them of minor works
     being undertaken on the site.


     Principle of development
35   The application site is a large vacant redevelopment site, which was previously
     occupied largely as offices and storage, including the London offices of J Sainsbury
     plc. Located in central London, with a previous substantial development on the site
     and a planning permission for a part 19 storey (90m AOD high) and part 7 and 5
     storey development for 43,856sq.m. offices and 2,418 sq.m. retail supermarket. This is
     a prime site for new intensive development.

     Appropriate uses on the site
36   The application site is within a Preferred Office Location in the Southwark Plan, which
     would oppose a loss of employment / office space to residential development.
     However, Policy 1.3 (Preferred office locations) would also allow for the development
     of the site for the arts, culture and tourism uses. A hotel would therefore be an
     appropriate use for the site.

37   London Plan Policy 3D.6 (Visitor accommodation and facilities) states that it is
     London’s Tourism Strategy is to achieve 36,000 additional hotel bedrooms by 2016
     and to improve the quality, variety and distribution of visitor accommodation and
     facilities. Policy 5B.2 (Development in the Central Activities Zone) states that boroughs
     should accommodate commercial development associated with business, tourism and

38   A study by the Greater London Authority indicates that around 2,500 additional hotel
     rooms will be needed in Southwark between 2005-2027. There are around 1,250
     rooms already planned for, but even if these are provided a shortfall still exists. There
     is therefore a need for hotel space in Southwark, particularly high quality
     accommodation, which this proposal will help to meet.
39   Both the London Plan and the Southwark Plan also support a mixed use development
     on this site, with residential accommodation. This proposal would be a mixed use
     development, in compliance with policy.

     Suitability of this site for a tall building
40   The Government encourages local authorities to identify suitable locations where tall
     buildings are, and are not, appropriate, in areas where such developments are a
     possibility. This is supported in the ‘Guidance on Tall Buildings’ (English
     Heritage/CABE 2003, updated 2007) as the plan-led approach to tall buildings.
     Unfortunately this work has yet to be done in Southwark and the planned ‘Tall
     Buildings Supplementary Planning Document’ will not be available for consultation for
     some time.

41   In the absence of an adopted supplementary planning document on tall buildings,
     which should address the planning issues and appropriateness of this area for tall
     buildings, we do have planning policies in the emerging Southwark Plan and the
     London Plan which set out criteria suitable for making decisions on applications for tall

42   The Southwark Plan policy 3.20 (Tall Buildings) states:
     Planning permission may be granted for buildings that are significantly taller than their
     surroundings or have a significant impact on the skyline on sites, which have excellent
     accessibility to public transport facilities and are located in the central activities zone
     (particularly opportunity areas) outside landmark viewing corridors. Proposals for tall
     buildings should ensure that there are excellent links between the building(s) and
     public transport services. Any building over 30 metres tall (or 25 metres in the Thames
     Special Policy Area) should ensure that it:
     1. Makes a positive contribution to the landscape; and
     2. Is located at a point of landmark significance; and
     3. Is of the highest architectural standard; and
     4. Relates well to their / its surroundings, particularly at street level; and
     5. Contributes positively to the London skyline as a whole consolidating a cluster
     within that skyline or providing key focus within views.

43   This application is for a development within the Central Activities Zone, outside
     strategic viewing corridors, in a location with excellent accessibility to public transport.
     The site also meets the criteria for a site of landmark significance and the proposal has
     been assessed by Council officers and by CABE as being of the highest architectural
     standard. CABE described this scheme as a bold addition to the London Skyline and
     believe that this island site at the bridgehead of Blackfriars is a suitable location for a
     tall building, provided that it is of the highest quality. They recommend that the quality
     of the detailed design, materials and finishes can be secured by conditions. How it
     relates to its surroundings and its contribution to the landscape and skyline are
     assessed in this report. In addition to the criteria in Policy 3.20, above, the Council has
     a statutory duty to consider the impact of the development on the setting of Listed
     Buildings, Conservation Areas and World Heritage sites, which will include those in
     neighbouring authorities.

44   Despite the absence of adopted supplementary guidance for tall buildings for this area,
     there is considerable pressure for such proposals and a number of tall buildings have
     already been permitted in the Bankside and Borough area. Notable an extension to
     Kings Reach Tower, 240 Blackfriars Road, Bankside 1-2-3, Bankside 4, and Tate
     Modern 2. This location is suitable for tall buildings as it meets the policy criteria. This
     specific site, at the end of Blackfriars Bridge, would be suitable for an appropriate
     landmark building of a high design quality.

45   London Plan Policy 4B.8 (Tall Buildings – Location) states that the Mayor will promote
     the development of tall buildings where they create attractive landmarks enhancing
     London’s character, help to provide a coherent location for economic clusters of
     related activities and/or act as a catalyst for regeneration and where they are also
     acceptable in terms of design and impact on their surroundings.

46   London Plan Policy 4B.9 ‘Large-scale buildings – design and impact’ adds that all
     large-scale buildings including tall buildings must be of the highest quality design and
     in particular: (a) be suited to their wider context in terms of proportion and composition
     and in terms of their relationship to other buildings, streets, public and private open
     spaces, the waterways or other townscape elements; (b) pay particular attention, in
     residential environments, to privacy, amenity and overshadowing; and (c) provide high
     quality spaces, capitalise on opportunities to integrate green spaces and planting and
     support vibrant communities both around and within the building.

47   English Heritage and CABE recommend the following criteria for considering
     applications for tall buildings:
     (i) The relationship to context, including scale, height, streetscape and skyline. Tall
     buildings should have a positive relationship with topographical features and other tall
     buildings; the virtue of clusters when perceived from all directions should be
     considered in this light;
     (ii) The effect on the whole existing environment, including the need to ensure that the
     proposal will preserve and/or enhance historic buildings sites, landscapes and
     (iii) The effect on World Heritage sites;
     (iv) The relationship to transport infrastructure, aviation constraints and capacity of
     public transport;
     (v) The architectural quality of the building, including its scale, form, massing,
     proportion and silhouette, facing materials and relationship to other structures;
     (vi) The sustainable design and construction of the proposal. Exemplary standards of
     design should be expected because of their high profile and local impact;
     (v) The credibility of the design, both technically and financially;
     (vi) The contribution to public spaces and facilities, both internal and external, that the
     development will make in the area;
     (vii) The effect on the local environment, including microclimate, overshadowing, night-
     time appearance, vehicle movements and the environment and amenity of those in the
     vicinity of the building;
     (viii) The contribution made to the permeability of a site and wider area; opportunities
     to offer improved accessibility;
     (ix) The provision of a high quality environment for those who use the buildings,
     including function and fitness for purpose; and
     (x) Other broader issues including access, means of escape and public safety

48   A criticism made by English Heritage is the absence of a tall buildings policy for North
     Southwark to base any judgment of the application upon. This site is not in an area
     identified as an opportunity area in the London Plan. The London Plan identifies only
     the area around London Bridge and Elephant and Castle as ‘Opportunity Areas’,
     where tall buildings would be appropriate. They argue that without a clear and up-to-
     date planning context, the consideration of proposals which would have cross-London
     impacts of this significance would be premature.

49   It is correct to say that tall buildings, due to their size, have a wider impact than just on
     the local environment. Due to their size and prominence, their impact can affect both
     neighbouring boroughs and/or the city as a whole. The greater the height, the greater
     and wider this impact may be. Therefore, this proposal will potentially have a
     significant impact for the whole of central London. This is both due to the great height
     of the building and also because of the context of the surrounding area, in particular
     the absence of any significant tall buildings on the north bank of the Thames near to
     Blackfriars Bridge.

     Environmental impact assessment
50   Distant views have been considered in detail. The main issues concern was the
     potential impact on conservation areas or the setting of listed buildings. This is
     considered later and found not to be significant or result in any adverse impact. The
     ability to see a distant view of this building would not, in itself, be an adverse impact
     that would justify refusal of permission.

51   Local views have also been considered in detail. The setting of listed buildings and the
     character and appearance of conservation areas has been of particular concern,
     particularly in Southwark, Lambeth and the City of London. Both Southwark officers
     and the City of London do not believe that there would be an adverse impact in
     Southwark or the City. Lambeth consider that there would be an adverse impact on the
     character of their conservation areas. However, as there are closer tall buildings and a
     proposal for a 140m tower at Doon Street, which are closer to these conservation
     areas it is difficult to see how this building would have such an adverse impact.

     Impact of proposed development on amenity of adjoining occupiers and
     surrounding area

52   The impact of the proposed development on the daylighting to the windows and
     balconies of nearby flats, especially Rennie Court, has been a major concern of many
     objectors. Compared to the present situation, where the site has been cleared of all
     buildings, almost any significant development on the site is likely to result in a loss of
     daylight to these neighbouring flats, and a loss of views across the site, compared to
     the existing undeveloped state of the site. However, this is an unrealistic situation and
     any assessment of the impact on daylighting must be judged by comparison with the
     situation when the previous buildings were on the site and also a comparison with the
     impact of the 2002/2006 consented development which could be built on the site.

53   A very detailed analysis has been carried out to assess the impact on every window
     facing this site in Rennie Court and River Court. The Vertical Sky Component (VSC)
     and Average Daylight Factor (ADF) calculations for every window have been assessed
     against the criteria set out in the BRE Guidance (Site Layout Planning for Daylight &
     Sunlight 1995), which are the criteria normally used for developments in Southwark. A
     comparison of both VSC and ADF figures for the proposed development indicates that
     there would be a very small, insignificant, reduction in daylighting to parts of Rennie
     Court from the pre-existing buildings and the 2002/2006 consented scheme. However,
     for River Court the proposed development would result in a small improvement on the
     pre-existing situation and near identical results as for the 2002/2006 consented

54   Overall, the results show that the impact on daylighting levels enjoyed by Rennie Court
     and River Court, as compared to the results for the previous buildings and the
     2002/2006 consented scheme, the proposed development is unlikely to have any
     further material adverse impact and the expected levels of daylight will be acceptable.
     Within Rennie Court some flats will not meet the daylighting standards in BRE
     Guidelines; this is because some of the balconies over the windows restrict the
     amount of light to a very low existing level, such that any small changes would appear
     to be larger than it actually is. Where this occurs in the existing situation, the results
     are still considered to be reasonable particularly given the urban context.

55   It should also be noted that the BRE Guidelines are not mandatory and are not
     intended to be an instrument of planning policy. The guidance also advises that in
     some cases a high degree of obstruction may be unavoidable if new developments are
     to match the height and proportions of existing buildings. In this case it is the lower
     floors of the proposed development, which are of similar height to Rennie Court, which
     will affect daylight to nearby windows and not the tower.

56   Overall, the results show that the proposed development would not result in a
     significant adverse effect on the sunlighting levels enjoyed by residents of Rennie
     Court and River Court. Within Rennie Court there will be some failures of BRE
     Guidelines but these will be the windows situated beneath balconies, which cast a
     shadow upon the windows beneath them. The results are considered more than
     adequate for an urban development located within the inner city where relevant
     planning policies promote high density residential development.

     Transient Overshadowing
57   The tower of the proposed development will cast a shadow over the residential
     properties to the west of the site (Rennie Court) for approximately one hour in the early
     morning through the summer; and will cast a shadow over residential properties to the
     north (River Court) for approximately two hours in the late morning throughout the
     year. Considering the urban context, it is considered that these results are acceptable
     and the development will not adversely affect the amenity enjoyed by residents of
     Rennie Court and River Court.

     Light pollution
58   Light spillage from the internal lighting of the proposed development is unlikely to be
     above that produced by the current street lighting around the site. The neighbouring
     residential buildings will be at least 20 metres away from the development and the
     level of light pollution is expected to be of negligible significance.

     Radio and television interference
59   An assessment has considered what effects the tower building will have for broadcast
     radio, terrestrial television and satellite television signals. These operate at different
     transmission frequencies and possess different transmission wave properties. The
     effects of tall buildings (and other large structures) on signals are principally in the
     following ways: (a) Shadowing effects, where an area behind the structure is
     effectively screened from the transmitter preventing reception of the transmission or
     reducing signal strength; and (b) Ghosting effects, where the transmission signal is
     reflected and scattered by a conducting surface on the structure. Signals arrive at the
     receiver out of synchronisation with the ‘direct’ signal and created second ghost
     images on television pictures. In addition, like light, any electromagnetic signal can be
     reflected or diffracted around objects, particularly with low frequency radio

60   An assessment of the future impact of the proposed development indicates that there
     should be no effect on radio broadcasts but potentially some impact on television
     reception. For terrestrial television transmissions from Crystal Palace and Croydon, a
     signal shadow zone would be expected to extend north west in the direction of
     Holborn, Farringdon and Clerkenwell for up to 11.9km and 13.4km in length for Crystal
     Palace and Croydon respectively. A significant part of this area would be commercial
     areas of the City and Camden with low density of residential accommodation.

61   Locally the residents in the eastern block of River Court could lose terrestrial television
     reception and reflection (ghosting) could affect the remainder of River Court and
     Rennie Court receivers. Satellite transmissions could also be affected. Signals are
     received from the Astra satellite (located 28.2 degrees east above the equator) so a
     transmission shadow would affect properties north of the proposed tower. As the
     shadow effect is less due to the steep signal interception and because satellite signals
     are far less affected by ghosting, only the eastern part of River Court is likely to be
     affected. Alternative provision by cable or a relocated satellite dish could readily
     restore reception without significant loss of service.

62   Overall, the assessment shows that there is a possibility that the proposed
     development could interfere with television reception, particularly terrestrial television
     signals, due to transmission shadowing to the north, while signal reflection effects are
     expected to be negligible. Local shadow effects on River Court and reflection effects to
     Rennie Court would be of a similar magnitude to those expected with the 2002/2006
     consented scheme. Although these are ‘worst-case’ scenarios and subject to
     uncertainty, there is a great deal of certainty about how these effects can be mitigated.
     This can be secured by a condition of any permission and/or planning obligation which
     would require appropriate surveys to be carried out before and after development to
     assess the likely impacts, and the appropriate measures needed to rectify and
     problems that occur.

     Wind effects
63   Buildings that are taller than their surroundings may deflect wind pressure from higher
     levels down towards street level. Strong winds may occur as the pressure escapes
     around corners and through openings. The degree to which this is important depends
     on details of both building shapes, in the context of their surroundings, and the relative
     direction of the prevailing winds.

64   A series of wind tunnel investigations have been made to quantify the level of
     windiness in and around the proposed development and to guide the design to ensure
     that conditions are acceptable. The assessments have considered pedestrian level
     wind conditions around the development, in terms of pedestrian comfort and safety
     (The ‘Lawson Wind Criteria’).

65   The results of the assessment show that wind conditions around the site are relatively
     benign, being tolerable for leisure walking or better even in the windier times of year.
     The conditions in and around the proposed development would be within the
     acceptable range of conditions that might be experienced walking around any city
     centre in the south of England and similar to those experienced on other streets in
     central London.

     Traffic issues
66   This area has very good access to public transport with a public transport accessibility
     level (PTAL) of 6a, which is the highest level of accessibility. There are several bus
     routes passing the site and Waterloo, Blackfriars and Southwark Stations provide good
     access to underground services. The Waterloo, Waterloo East, Blackfriars and
     London Bridge Railway Stations provide rail services.

67   The development proposes a total of 29 car parking spaces for the 96 flats (30%
     provision) and a total of 50 spaces for the 261 bedroom hotel (reduced from 65 applied
     for). Although, town centre hotels should not generally have on-site parking provision,
     Jumeirah state that this will be a ‘5-star-plus’ hotel which will provide a level of service
     significantly in excess of the majority of hotels in London. They state that their
     requirement is therefore different to those of an average hotel, for which the policy
     would be more applicable. The provision will be 1 space per 5 bedrooms, which is well
     below the current provision at comparable hotels in Central London. The hotel will
     manage parking with a valet service and the expected number of trips generated is
     expected to be very low. The vehicles parked would include hotel cars, hired cars and
     chauffer driven cars, and some private cars. The hotel intends to have three Jumeirah
     badged limousines for airport transfers, theatre transfers and corporate business. It is
     anticipated that guests will use the secure parking but generally use taxis and public
     transport during their stay.

68   There will also be 112 secure bicycle parking bays and 24 motorcycle bays in the
     basement, and a street level store for 36 bicycles, in Rennie Street, for occupiers of
     the affordable flats. Ten Sheffield type cycle stands would also be provided in Rennie
     Street for visitors.

69   All car and motorcycle parking will be controlled by valet parking arrangements,
     located in two positions. Valet parking for hotel guests will be from the hotel drop-off
     point on Blackfriars Road. Here there will be a slip road with 5 car spaces at the hotel
     entrance and staff will park vehicles left here by guests. The second location, for
     residents, is in Upper Ground where residents can leave or collect their car at an off-
     road lay-by for two vehicles and staff located in a security room on the corner of Upper
     Ground and Rennie Street will park or collect cars from the basement car park. This
     valet parking arrangement will need to be part of a parking management agreement to
     ensure that no on-street parking congestion occurs.

70   Servicing will also be off-street using two lorry lifts to the basement delivery and
     storage areas. A Servicing Management Plan will be required for this development to
     ensure that deliveries are scheduled and distributed throughout the day in order to
     reduce the vehicle demand at peak times and to avoid the likelihood of waiting
     vehicles causing delay and disruption to the surrounding highway network. With the
     appropriate level of management of car parking and servicing and deliveries, the
     parking and traffic problems feared by some objectors living in the nearby flats should
     be avoided and any disruption minimised.

71   In order to minimise disruption to the movement of traffic, including buses, cyclists and
     pedestrians, during the construction phase of the development a construction
     management plan will also be required and agreed by TfL and the Council prior to
     work starting on the site.

72   A Travel Plan is proposed for this development and this will need to be secured,
     enforced, monitored and reviewed as part of the Section106 agreement for this
     development. Further details will be required by a condition, particularly for the Travel
     Plan targets and method of monitoring.

     Design issues
73   The architect, Ian Simpson, has designed this tower development to be both a
     landmark and a place that is comfortable and visually satisfying, using a number of
     architectural themes. The tower has evolved as a piece of sculpture to create a
     dynamic form, which combines gentle curved folds with straight lines. The tower has
     been designed to be seen in the skyline as a single object in relation to other tall
     buildings. The singular nature of the form is emphasised by the tapering and radiating
     lines of the glazing mullions which expand and contract with the shaped. The
     proportions of the tower have a vertical emphasis extending from the cladding units to
     the stacking of the louvre components to create vertical stripes on the façade of the
     building. The creation of abstract patterns of solid and clear cladding panels set within
     the controlling grid of the outer skin of the tower creates a unique building image. The
     Layering and depth of the tower is reinforced by the use of colour on the outside face
     of the inner skin. The colours express vertical movement becoming lighter with the
     increasing height of the tower.

74   The applicant’s design statement advises that the following factors influenced the form
     of the tower:
     (a) Linearity – the tower emphasises the strong linearity of both the bridge and
     Blackfriars Road, which is appropriate to its position;
     (b) Elegance – the tower is slender and elegant when seen from all London
     (c) Rights of light –the footprint of the tower had to be narrow at the base in order to
     respect rights of light for residential properties at Rennie Court and River Court;
     (d) Mixed use – the proposed functions within the tower are appropriate to a slender
     form as compared with an office floor plate.
     These four factors explain the thin cross sectional profile contrasted with a tapering
     longitudinal sectional profile that widens from a narrow base to a wide point two thirds
     up its height. From this point the rear façade of the tower angles inwards and drives
     skyward to create a dramatic culmination to the sky.

75   The façade of the tower would consist of two independent skins with a winter-garden
     zone between. The inner skin would be made up of a combination of double glazed
     elements and coloured insulated panels. The outer skin would be fully glazed with full
     height single glazed units. The twin skin helps to minimise energy consumption by
     acting as an insulation buffer in the winter and a naturally ventilated break-out zone in
     summer, therefore reducing the times when either heating or cooling is required.

76   The buffer space between the inner and outer layers of the building allow for ‘break-
     out’ areas, or ‘winter-gardens’ for both the residential apartments and the hotel rooms.
     These areas are protected from the wind and rain but have natural ventilation
     therefore giving the occupiers a sense of outdoor space whilst living high above the
     city, an experience not available to users of conventional balconies.

77   The double skin allows the use of a mixed mode heating and ventilation system, with
     the ability to open the glazed doors in the inner skin and the louvres in the outer skin.
     The double skin creates a protected zone for the solar control blinds. Heat that is
     halted by these blinds between the two skins can escape the building through the
     louvres of the external skin. The floor slab of the winter-garden above also shades the
     windows of the floor below. heating load is decreased in winter when openings in both
     skins are closed. Heat from the façade zone is then radiated into the interior space.
     Whilst the outer skin s fully glazed this is not a fully glazed building as at least 25% of
     the area of the inner skin of a particular residential unit or hotel floor is made up of
     opaque insulated panels.

78   The external skin ends in a ‘skirt’ suspended above the ground. This allows the form of
     the tower to float above the landscape and to expose the impressive concrete
     structure as it emerges from beneath the outer skin. The skirt also provides a degree
     of protection to the residential and Sky Deck entrances. The entire outer skin is a
     continuous system of unitised aluminium elements. In the case of the Sky Deck and
     the Skirt these units are fixed to the secondary steelwork that is fixed to the primary
     concrete structure. The façade at the base of the tower, below the ‘skirt’, is set back
     behind expressed concrete columns and will be conventionally double glazed.

79   Although the design and form of the tower has been a major factor in the design of the
     whole development, it was acknowledged from the outset that the way the tower
     meets the ground was a crucial element of the design, as would be the activity and
     functions at ground level. The low rise buildings, consisting of the podium and the
     Rennie Street Block form the solid base for the development upon which the tower
     stands. The hotel entrance and canopy facing Blackfriars Road is a separate
     architectural element. Most of the top surface of the podium forms a public Plaza,
     partially enclosed along the Stamford Street and Blackfriars Road boundary by an
     ‘inhabited wall’ element. Flights of stairs give access to the Plaza from the south and
     north, with lifts adjacent to the stairs ensuring full accessibility.

81   The fluid plan and elevation of the podium are in keeping with the shapes of the tower
     and the Rennie Street Block. The podium will be constructed from a thick wall of fair-
     faced concrete with a light coloured natural stone aggregate. The paving material
     proposed for the Plaza and the steps to the plaza will be similar in appearance to the
     walls and the aggregate used in the concrete elevations.

82   In order to achieve the optimum environment for the public pavements around the site,
     no ventilation louvres will be located below 5m above street level. Ventilation extracts
     from kitchens at ground floor level and in the basement will be through the roof of the
     retail units accommodated within the inhabited wall, and disguised by horizontal stone

83   The development includes a landscaped plaza, with public art, and tree planting along
     both Rennie Street and Upper Ground. Extensive public realm improvements are
     included for the adjoining road frontages, and included in a S106 planning obligation.

84   Impact on character and setting of a listed building and/or conservation area
     The Council has a statutory duty to give special consideration to how this development
     may impact upon the setting of listed buildings, world heritage sites, and the character
     and appearance of conservation areas, both in Southwark and in other boroughs. The
     planning application was accompanied by a comprehensive Environmental Impact
     Assessment (EIA) that included an assessment of the impact of the development on
     relevant nearby listed buildings and conservation areas. This also included an
     assessment of the impacts on strategic and local views, and views along the Thames
     (‘River Prospects’ identified in the London Plan). A more detailed study of how the
     development will impact on World Heritage sites has been submitted as an addendum
     to the original EIA.

85   The objections by English Heritage and Westminster City Council concern the
     potential impact on conservation areas, the setting of listed buildings and the
     Westminster World Heritage site. The Royal Parks also express concern about the
     impact on a St James’s Park viewpoint. The City of London, which also has listed
     buildings and conservation areas relatively nearby, does not object.

86   Both the Whitehall and St James’s Conservation Areas are some distance from the
     application site and so the impact of the development will be that it will appear in
     distant views from within these areas. Conservation Areas in Westminster comprise
     areas of dense urban development with few opportunities for long range views but a
     few specific sites are more sensitive than others and have been considered in detail.

87   One such view that is considered sensitive by these objectors is from the footbridge in
     St James’s Park, which is within the Royal Parks Conservation Area. From here, the
     view east (ENE) towards this site is currently of the lake terminating with an almost
     complete screen of trees, particularly those on Duck Island. Above these can be seen
     Horse Guards and the roofs of Whitehall Court beyond. The London Eye is the only
     modern structure in this view. The Shell Building being hidden by the Foreign Office
     building. The top of One Blackfriars Road would just be visible, with its tapering form
     seen just above the tree line as a distant view. Its smooth glass skin will not be
     confused with the heavy masonry of the classical buildings in the foreground. In future,
     the tops of 122 Leadenhall Street and the Bishopsgate Tower will also be visible, and
     the extended Kings Reach Tower will rise in the foreground of One Blackfriars Bridge.
     The London Eye will continue to be the one modern development that would catch the

88   Having considered the impact of the development, and the cumulative impact of other
     approved developments, on this view it is difficult to see how there can be any adverse
     impact. The scene will continue to be predominantly of the lake and the trees
     surrounding it, and the glimpses of both the old Whitehall buildings and new
     developments would at worst raise some curiosity in the viewer. However as One
     Blackfriars will be a distant view its impact would be insignificant. The concern that the
     sky deck and high windows, when illuminated, would contribute to ‘light leakage into
     the park’ is impossible at this great distance. A glow from the Sky Deck and high level
     windows may be visible from the Park at night but would be set against the glow of
     London lights in the same scene. The red warning lights for aircraft may be just as
     visible and equally have a negligible effect on the night scene. However, what people
     will see at night is the brightly lit London Eye and the Horse Guards buildings, and
     some flood lighting of the park trees. One Blackfriars Road will have no impact on that

     Views from other Conservation Areas.
89   The impact on seven Conservation Areas in Southwark, three in Lambeth and eleven
     Conservation Areas in the City of London were also considered. In Westminster, in
     addition to the Conservation Areas around Whitehall, the Savoy and Strand
     Conservation Areas were also considered. In none of these cases was it considered
     that there would be an adverse impact on the setting of listed buildings or the
     character or appearance of the conservation areas.

     The Westminster World Heritage Site.
90   Another sensitive view from Westminster would be that from Parliament Square and
     whether One Blackfriars Road would have an adverse impact on any views of the
     Parliament buildings or Westminster Abbey. As this is an objection formally made, a
     detailed photographic study has been carried out to see whether any of the views of or
     from the World Heritage site or Parliament Square are harmed. The World Heritage
     site does not include Parliament Square but does include Westminster Abbey, St
     Margaret’s Church and all the buildings around them, and all the buildings comprising
     The Palace of Westminster (north of Victoria Tower Gardens).

91   One Blackfriars Road will not be visible from anywhere within the boundary of the
     World Heritage Site, except for the private river terraces of the parliament buildings. It
     will be impossible to see One Blackfriars Road in any of the classic ‘picture post card’
     views of the Abbey or Big Ben, or indeed any important view. It may just be possible to
     glimpse the building from within Victoria Tower Gardens, which is outside the World
     Heritage site, but only if you know where to look for it. The view from the middle of
     Lambeth Bridge along the River would see the World Heritage buildings clearly to the
     left (north) and the London Eye and St Thomas’s Hospital to the right. The top of One
     Blackfriars Road would appear further to the right, not in the direct line of sight, as a
     distant view and would not be particularly noticeable. Although objections have been
     made about the impact on the World Heritage site, this has now been checked and
     demonstrated that there would actually be no impact.

     Tower of London World Heritage Site.
92   Although there has been no suggestion that One Blackfriars Road would have an
     impact on the Tower of London, nor any objection submitted, this possibility has also
     been considered as part of this application. An assessment can be made from the
     ‘River Prospect’ views supplied with the application, in particular those from Tower
     Bridge. From this elevated view One Blackfriars Road will be seen in the distance,
     forming a new cluster of tall buildings next to Kings Reach Tower and possibly 20
     Blackfriars Road in the future. This cluster would be insignificant in this view compared
     to those existing and proposed in the City and at London Bridge Station. Photographs
     from within the Tower of London (used for assessing the impact of the London Bridge
     Tower) demonstrate that One Blackfriars Road would not be visible from key views,
     except possibly from the south side of the White Tower. Even here the view would be
     distant and insignificant compared with much closer developments.

93   There would therefore be no adverse impact on either of the Westminster or Tower of
     London World Heritage sites.

     Affordable Housing
94   Affordable housing would be provided both on-site and off-site. The upper floors of the
     tower would be occupied by 96 market sector apartments and the Rennie Street Block
     would be occupied by 32 affordable ‘intermediate’ units, comprising one and two
     bedroom apartments, including four suitable for mobility impaired occupants. All of
     these would be built to Lifetime Homes Standards. The affordable housing equates to
     11.9% of gross habitable floor area. These units would be completed and transferred
     to one of the Council’s nominated registered social landlords (RSL) prior to the
     occupation of more than 50% of the market housing to be provided on the site.

95   The remaining affordable housing will be provided off-site and comprise social-rented
     units to be transferred to one of the Council’s nominated RSL’s prior to occupation of
     85% of the market housing. The developer intends to secure a site or sites locally for
     off-site affordable housing units. The amount of accommodation being limited to a
     financial value of £51.62m. It has been agreed that when this development is reported
     back to Committee (in October) a site needs to have been identified.

96   It has not been possible to provide all the required affordable housing on the site due
     to the design of the development and constraints of the site. To provide more
     accommodation on the site would be very difficult The servicing, management and
     insurance costs associated with apartments in the upper floors of the Tower would
     make them too expensive to be affordable. It is not possible to provide additional
     accommodation in the Rennie Street Block without serious adverse affects for the
     existing residents of Rennie Court, due to further loss of daylight to their flats.

     Planning obligations [S.106 undertaking or agreement]

97   The applicants have agreed to the following Heads of Terms for a planning obligation:
     Affordable Housing: In addition to 32 intermediate housing units on-site, and off-site
     provision as described above.

     Education: A sum of £114,692 to support school places based on the draft SPD.

     Employment in the development: A sum of £158,170 based on the draft SPD, to
     provide £58,170 for a Workplace co-coordinator and £100,000 for bursaries for
     unemployed residents to attend Hospitality and Training courses at Southwark

     Employment during construction: A sum of £62,434 based on the draft SPD.

     Public Open Space: A sum of £94,707 based on the draft SPD and will provide
     improvements to open space, children’s play equipment, sports development in the
     local area. The development will also provide a new public plaza which will be
     provided by the developer at a cost estimated to be £2,713,183.

     Strategic Transport contribution: A sum of £132,720 based on the draft SPD.

     Transport - site specific: £2,759,000 towards the Blackfriars Road Boulevard scheme
     from Blackfriars Bridge to Stamford Street.

     Public realm: A sum of £3,219,000 is proposed to include highway and public realm
     improvements to the surrounding roads, in particular:
     - £992,000 towards improvements to Rennie Street and Upper Ground, and provision
     of a new pedestrian crossing at the junction of Stamford Street and Blackfriars Road;
     - £1,227,000 towards improvements to Blackfriars Road and Stamford Street and the
     provision of two new traffic islands.

     Health: A contribution of £86,496 in line with SPD formulae;

     Community Facilities: A sum of £1,000,000 towards the ‘Community Project Fund’ to
     be spent on local community facilities over 5 year period.

     Community Facilities: £13,505 for other facilities in line with SPD calculations;

     Public Art: A sum of £300,000 will be used to fund the proposed art installation at the
     centre of the public plaza;

     Tourism: A sum of £150,000 towards tourism and visitor management measures;

     Administrative charge: A sum of £109,581 for monitoring and administering the S106.

98   The total of the financial contributions proposed comes to £8,067,719. Together with a
     potential in-lieu payment for provision of affordable housing in the local area* of
     £15,620,000, the value of the total contribution would be £23,687,719. (*It is
     recommended that the ‘local area’ is defined as the area of the Borough and Bankside
     Community Council.)

     Other matters
99   A great many additional details have been examined in considering this unique
     proposal. All these matters have been satisfactorily resolved and include the following:
     (a) Means of escape. In the case of fire or other extreme events the main method of
     evacuation will be by lifts, mainly fire lifts. However, all apartments will be fire
     protected cells where occupants can wait safely until rescued. The building is
     designed to withstand any reasonable extreme event without major structural failure;
     (b) There will be publicly accessible WC facilities at ground level within the hotel lobby
     as well as on level 50 for visitors to the Sky Deck;
     (c) Sky Deck illumination will be kept to a minimum. As the main purpose of the Sky
     Deck is to provide clear views over London, internal lighting within the observation
     deck at night needs to be kept low in order to reduce glare and reflections for visitors
     looking out. (Details can be covered by a condition) ;
     (d) Access to the public plaza will be 24hrs a day, 7 days a week, except for
     occasional private events or special circumstances. This will be secured by the
     planning obligation. It is intended to use the plaza for a range of activities including
     sculptures, exhibitions and potentially live music. As the plaza faced on two sides by
     accommodation within the development the level of noise will be carefully controlled.
     Management of the whole site by the hotel will ensure that such co-ordination occurs.

100 The proposed development will by its sheer size be a London landmark. Its unique
    architectural form will also make it stand out. However, the slender sculptural form and
    high standard of detailed design will make this an attractive addition to London’s
    skyline, not an eyesore. With the ‘Shard’ and the ‘Gherkin’, this tower building will be a
    positive example of modern architecture and another feature of London as a
    progressive world city. It will also be another signal, among many others, that Inner
    City regeneration and investment is occurring in Southwark, on the south bank of the
    Thames and not just confined to the City and north London.

101 Although the proposal has come forward before any new policy for tall buildings in this
    area could developed, the existing policies of the London Plan, emerging Southwark
      Plan and guidance from CABE/English Heritage are adequate for considering this
      proposal, and this scheme does comply with existing policies and guidance.

102 Concerns expressed by Westminster and English Heritage about the impact on the
    character of conservation area and other interests have been closely examined and
    not considered to provide any justification to reject this proposal. The fact that a new
    building can be seen in the distance is not, in itself, justification for refusing permission
    for that building. In the case of the objection to the impact on the Parliament Square
    World Heritage site, the new building could not be seen from any public area within the
    site. All these objections and other considerations have been considered in detail but
    no adverse impact has been found.

103 Similarly, there will be some local impacts particularly affecting Rennie Court and River
    Court. However, issues about loss of daylight to windows or views of St. Paul’s across
    the site are only in relation to the recent circumstances of the whole site being cleared.
    It would be unrealistic to expect such a large site in central London to remain vacant,
    indeed there already is a planning permission for a substantial development on this
    site. An analysis of the impact of the proposed new development compared with either
    the previous buildings on the site or the development granted permission in 2002 and
    2006, demonstrates that the difference between the proposal and alternative situations
    would be insignificant. This scheme also improves on the public open space, public
    realm improvements and provision of affordable housing that would have been
    provided in the alternative development.

104 A planning obligation will provide substantial contributions to mitigate against any
    adverse effects that may occur from this development. As there are no policy
    objections and no adverse impact on the amenity for neighbouring residents or the
    surrounding area the proposed development can be recommended for approval


105 In line with the Council's Community Impact Statement the impact of this application
    has been assessed as part of the application process with regard to local people in
    respect of their age, disability, faith/religion, gender, race and ethnicity and sexual
    orientation. Consultation with the community has been undertaken as part of the
    application process.

      a]   The impact on local people is set out above.

      b] The following issues relevant to particular communities/groups likely to be affected
      by the proposal have been identified as increased traffic and pedestrian movements,
      noise and disturbance and reduced daylighting to some windows.

      c] The likely adverse or less good implications for any particular communities/groups
      have been also been discussed above. Specific actions to ameliorate these
      implications are improvements to the public areas around the building, whole
      development designed to minimise impact on neighbours and contributions to provide
      affordable housing, employment training and improve community facilities in the area.


106 The scheme provides a sustainability package which is exemplary for a number of
    reasons. Firstly, the building envelope has been designed to make this development
    one of the most inherently low-energy buildings in London. The whole development
    will be triple glazed, incorporating glare and solar control that can be adjusted to suit
    all weather conditions. Air leakage is greatly reduced. In winter, heat loss is minimised
    whilst providing control over useful passive solar energy. In summer, unwanted solar
         gain is virtually eliminated.

   107 Measures to reduce energy demand result in a CO2 saving of 22%, with a further
       reduction in CO2 emissions of 26% due to renewable energy technologies. The total
       CO2 saving is 43% which is comfortably in excess of current policy requirements.
       Part L (2006) calculations (SAP) have been carried out for typical affordable housing
       apartments and indicate that this super efficient envelope combined with low-energy
       lighting, CHP, solar water and wood-fired community heating will result in carbon
       dioxide emissions 60% lower than the new (demanding) target emissions. Running
       costs will be substantially reduced. The scheme will exceed anticipated future GLA
         Biomass heating will provide 50% of forecast peak demand and 80% of annual energy
         demand. This would be a major renewable energy contribution. This would be backed
         up by a gas fired CHP plant. Whilst not a renewable energy source, the higher
         efficiency of this plant would produce carbon emission savings of 7%.

         Solar water heaters will be provided on the roof of the Rennie Street block. Each of the
         32 affordable residential units in Rennie Street would be provided with a 3 sq.m.
         evacuated tube solar collector located on the roof to provide a portion of the domestic
         hot water load within each apartment.
         Photovoltaics will be used on the upper part of the south façade of the tower. The
         photovoltaics would be integrated within the outer laminated glazed skin using thin-film
         technology. An area of about 100 sq.m. is proposed. Although this may only produce
         0.05% of the renewable energy contribution, photovoltaics are a highly visible form of
         renewable energy and can provide an element of solar shading. As there will be some
         tuning of the proposed siting of these panels, this will be submitted for approval by
         It is also intended to use sustainable materials:
         - For BREEAM and Ecohomes it has been assumed that hard landscaping will be A
         - A significant proportion of aggregates to be used are formed from recycled materials;
         - Internal walls and partitions will be timber or metal stud or another A rated material;
         - 75% of the timber used will be FSC, while the remainder will be sourced from
         temperate forests. No tropical hardwoods will be used.

   LEAD OFFICER           David Stewart                Interim Head of Development and
                                                       Building Control
   REPORT AUTHOR          Adrian Dennis                Team Leader Development Control [tel.
                                                       020 7525 5445]
   CASE FILE              TP/1234-E1
   Papers held at:        Regeneration Department, Council Offices, Chiltern, Portland Street
                          SE17 2ES [tel. 020 7525 5403]

APPENDIX 1: Comments from Exhibitions

Questionnaires were available at all three pre-application exhibitions, this is a summary of the results
from those submitted:
Exhibition 1 – May 2005: 30 people completed questionnaires for the first exhibition
                                                Agree       Agree         Neutral      Disagre

 The site requires a high quality scheme               26          4
 It is important that the scheme provides for
 London and local people                               24          4           1
 This site requires a scheme that will enhance
 the Blackfriars Road                                  22          7           1
 Daylight and traffic are major issues in this
 development                                           19          7           2          2
 This site is an opportunity for a landmark
 development.                                          18          6           5

Exhibition 2 – September 2005: 27 People completed the questionnaires for exhibition 2
                                               Agree      Agree       Neutral       Disagre

 Welcome the jobs that this scheme will bring          12          9           7          3
 Welcome a residential scheme rather than an
 office block                                          12          8           8          3

 The Plaza area and shops will be welcome              12         17           2
 Right of Light issues have been thought about in
 this development                                      1          13           7          9
 The Beetham Building will enhance the local
 area                                                  11         12           3          5

 The scheme is a beautiful building                    14          7           6          4

Exhibition 3 - October 2006: There were only 12 responses to the questionnaire
                                                  Agree     Agree       Neutral        Disagre
 The new public plaza area layout has improved
 and the shops will be a welcome addition to the       5           7
 The new hotel drop off area on Blackfriars Road
 will ease congestion on Upper Ground                  2           9                      1
 The new height of the tower is more in keeping
 with the local area                                   3           5           4
 Right of Light issues have been thought about in
 this development                                      1           5           6
 The Beetham building and the Jumeirah Hotel
 will enhance the local area                           5           5           2

 The scheme is a beautiful building                    3           8           1

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